Private International Law

Abstract This chapter focuses on private international law, emphasizing jurisdiction, choice of law, and the recognition and enforcement of foreign judgments, particularly in the context of the UK’s exit from the European Union (Brexit). It begins by discussing the complexities of applying domestic private law to transnational issues, highlighting the misalignment between territory and the law applied. The chapter explains how jurisdictional rules allocate authority to hear disputes, also addressing the implications of Brexit on these rules. It further examines the differences between common law and civilian approaches to jurisdiction, particularly in relation to the Brussels Regime and the Lugano Convention. Finally, the chapter explores the evolving landscape of jurisdictional regimes after the UK’s departure from the EU, focusing on their effects on cross-border legal matters.